The Innovative Payments Association (IPA) recently submitted an unsolicited comment letter to the Federal Communications Commission (FCC), commending the agency’s decision to delay the implementation of a controversial component of its Telephone Consumer Protection Act (TCPA) ruling. While the overall rule remains in effect, the FCC issued a one-year stay on the provision requiring companies to cease all communications once a consumer revokes consent—regardless of the message type or business unit involved.

The IPA supports this delay and encourages the Commission to use this time to evaluate the practical and potentially harmful implications of this “revoke all” standard.

Key Concerns Raised by IPA:
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• Overbroad Interpretation Risks Consumer Harm: A single “stop” response from a consumer could unintentionally block critical communications from financial institutions—such as fraud alerts, overdraft notices, or multi-factor authentication prompts—placing consumers at risk.
• Operational Challenges for Financial Institutions: The provision requires companies, including small institutions with limited resources, to coordinate and technically overhaul their communication systems across multiple business units and third-party vendors.
• Lack of Cost-Benefit Analysis: The FCC did not assess the compliance burden, particularly on smaller entities, nor did it consider the broader consumer protection implications of halting vital messages.
• Ambiguity Around Consent Revocation Scope: The rule provides no clear mechanism for financial institutions to verify or clarify the scope of a consumer’s opt-out, which may lead to over-correction and silencing of important messages unintentionally.
  
  

A Call for Smart, Safety-Oriented Policy

The IPA’s letter is not a rejection of consumer rights or consent controls. Rather, it calls for measured policymaking that reflects the complexities of modern financial communications. By reevaluating the “revoke all” requirement through a more transparent and practical lens, the FCC can better protect both consumers and the institutions that serve them.

Read the Full Comment Letter

To learn more about the IPA’s position and the recommendations submitted to the FCC, you can read the full letter.

On March 20, 2025, the Innovative Payments Association (IPA) submitted a formal comment letter to the Consumer Financial Protection Bureau (CFPB) in response to the agency’s proposed interpretive rule regarding the application of the Electronic Fund Transfer Act (EFTA) and Regulation E to emerging payment mechanisms. The Proposed Rule, issued in January 2025, would significantly expand the scope of Regulation E to include cryptocurrencies, digital assets, and even credit card rewards points.

While the IPA supports strong consumer protections, the association is concerned that the rule, as proposed, is overly expansive and lacks the rigorous study and stakeholder input that should precede such a substantial shift in policy.

Key Concerns Raised by IPA:

• Overreach and Limited Input: The rule represents a sweeping expansion of Regulation E that may have been issued without sufficient data or engagement with affected stakeholders.
• Impact on Consumers: The Proposed Rule could unintentionally remove beneficial products—such as credit card rewards—from the market, limiting consumer choice.
• Timing and Transition: The rule was issued shortly before a change in administration. IPA believes the new leadership should have the opportunity to evaluate and guide such a significant policy change.
  
  

The IPA has requested that the CFPB withdraw the Proposed Rule and, if further action is warranted, pursue a more transparent and inclusive rulemaking process.

A Call for Thoughtful, Collaborative Policymaking

IPA’s recommendation is not a call to weaken consumer protections. Rather, it is a call for deliberate policymaking that carefully balances innovation, inclusion, and consumer safety. By engaging with industry experts and gathering broad input, the CFPB can develop effective, forward-thinking regulations that support both consumers and the evolving payments ecosystem.

Read the Full Comment Letter
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To learn more about the IPA’s position and concerns, you can read the full letter.

The Innovative Payments Association (IPA) has submitted a comment letter to the Federal Election Commission (FEC) addressing a proposed rulemaking related to contributions made using prepaid cards. While we recognize the importance of maintaining transparency in campaign financing, the IPA emphasizes that prepaid cards are already issued by highly regulated entities and are subject to stringent compliance under the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) requirements.

Prepaid accounts play a critical role in financial inclusion, offering millions of unbanked and underbanked Americans access to secure and efficient financial tools. These accounts are particularly valuable for individuals and government programs, delivering faster and safer transactions than traditional methods. The proposed amendments could inadvertently stigmatize these essential tools, limiting their use and impact.

Key Points from the IPA's Comment Letter:

• Prepaid accounts are issued by regulated institutions and comply with comprehensive BSA/AML requirements.
• Reloadable prepaid cards offer transparency and security, with tracking mechanisms comparable to debit and credit cards.
• Millions of Americans rely on prepaid accounts for their everyday financial needs, including political contributions.
• Government programs, such as the U.S. Treasury’s Direct Express initiative, have successfully adopted prepaid tools to improve efficiency and cost-effectiveness.

​We encourage you to read the full comment letter to explore how the existing regulatory framework addresses concerns raised in the petition, ensuring prepaid accounts remain a trusted and inclusive financial tool.

The Innovative Payments Association (IPA) has submitted a letter to the Federal Deposit Insurance Corporation (FDIC) addressing the proposed rule on recordkeeping for custodial accounts with transactional features. This rule is intended to enhance the FDIC’s ability to determine deposit insurance coverage quickly in the event of an institution's failure.

In our response, we acknowledged the importance of the proposed rule while urging the FDIC to refine its scope. Specifically, we recommended excluding products like gift cards, single-load payment devices, and similar offerings that do not function as substitutes for traditional deposit accounts. We also highlighted concerns about the potential compliance burden and suggested extending the implementation period from one to two years.

To learn more, download the comment letter.

Stay informed about developments in the financial services industry by following the IPA.

The Innovative Payments Association (IPA) recently submitted a comment letter to the FDIC concerning proposed rule changes to brokered deposits. We voiced strong concerns about the elimination of key exceptions, such as the "Enabling Transactions Exemption" and exclusive deposit relationships, which have provided essential clarity and promoted financial innovation. IPA urged the FDIC to retain these exceptions to avoid stifling fintech-bank partnerships that have expanded consumer access to critical financial services.
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Moreover, treating fintech deposits as inherently risky "brokered deposits" threatens innovation and limits consumer options. We emphasize the need for data-driven analysis and further study before implementing changes that may adversely impact consumers, innovation, and competition in financial services.
For more details, download the comment letter.